CA ANZ supports the objective of strengthening transparency and accountability for modern slavery and forced labour risks, particularly within global supply chains. Its submission to the Education and Workforce Committee highlights the importance of a proportionate and practical regime that aligns with comparable international frameworks.

CA ANZ recommends that the proposed regime align with existing modern slavey reporting frameworks in Australia and the United Kingdom, including allowing an equivalent Australian or UK statement to be used where the core disclosure content is materially aligned.

The submission also recommends aligning the New Zealand reporting period with an entity’s financial reporting cycle. This would reduce duplication for entities operating across multiple jurisdictions and allow reporting to be prepared through established governance and reporting processes.

CA ANZ has concerns about uncertainty in the Bill regarding whether reporting entities would be required to undertake due diligence. It recommends that the regime initially remain focused on disclosure of entities’ frameworks, processes and risk management approaches, rather than prescribing or enforcing substantive due diligence outcomes.

The submission also highlights the potential impact on small and medium sized enterprises within the supply chains of larger reporting entities. CA ANZ recommends guidance that ensure implementation remains proportionate to risk, capability and the practical realities of supply chains.

CA ANZ supported phased implementation, with clear guidance and practical examples and an initial focus on education and capability building. The submission calls for greater clarity around group reporting and the governance of the regime, including responsibility for enforcement, guidance and victim support.